by Jim Ewing
1. The National Postgraduate Committee of the United Kingdom (NPC) welcomes the opportunity to respond to the draft Higher Education (Northern Ireland) Order 2005.
2. The NPC is the primary representative body of postgraduate researchers and students in the United Kingdom. Our affiliate membership comprises of democratically-elected student representative bodies at Higher Education Institutes (HEIs) throughout the UK. As a registered charity (SCO33368), our aim is the promotion of postgraduate education in the United Kingdom. In order to achieve this aim, we host and address conferences, share best practice through publications and meetings, respond to consultations and campaign on issues of concern to postgraduates. We also co-operate with other democratic student bodies and trades unions who share our aims.
3. We reiterate that NPC is a charity with the declared aim of the promotion of postgraduate education in the United Kingdom; the draft Order only comes directly under our remit in as far as it covers trainee teachers on initial training courses [3-1]. While this is enough to merit our responding, we still see fit to respond to the wider scope of the draft order, as policy which directly affects undergraduate higher education now will indirectly affect postgraduate higher education in the near future.
4. We appreciate that the draft Order is intended to protect the interests of students by regulating the charging of tuition fees by HEIs above a basic rate (i.e. top-up fees). We view Article 11, which prevents the writing off of student loan debt by the declaration of bankruptcy, in a similar light. To this extent, the draft Order seems to us a commendable exercise in damage limitation, which phrase we use advisedly, as we remain fundamentally opposed to the introduction of top-up fees.
5. Top-up fees we believe to be socially divisive and to pose a potentially great threat to higher education in the United Kingdom. Already levels of debt incurred by undergraduates are such as to deter students from poorer socio-economic backgrounds from aspiring to higher education as the poor are much more wary of debt than are the middle classes; the very idea of top-up fees is enough to make many dismiss the possibility of higher education.
6. This is of great concern to NPC as the undergraduate and postgraduate phases of higher education are more closely linked than many realise. Firstly, and most obviously , the more people are deterred from commencing higher education, the fewer graduates there will be to proceed to postgraduate education and, while some sectors of postgraduate education receive far more applicants than can possibly be accommodated, any drop in applicants means a smaller pool from which the most talented and able can be drawn. In the worst cases, there may not be sufficient applicants of sufficient quality to sustain research staff, who also teach undergraduates and whose dismissal on economic grounds results in curtailment of undergraduate courses, possibly with the loss of entire subjects in certain HEIs (which phenomenon we are already beginning to see for other reasons before the effect of potential top-up fees even has a chance to kick in) and fewer people from poorer backgrounds applying for higher education as their preferred courses - possibly even their only academic options - are no longer available locally and they cannot contemplate the expense of travel or relocation. While the draft Order may be a commendable attempt to make the charging of top-up fees as fair as possible and to dissuade the financially inexperienced from developing a lackadaisical attitude towards bankruptcy, we remain fundamentally opposed to the policy the effects of which this draft Order attempts to ameliorate and urge an urgent re-think on the policy of providing extra funds for higher and especially postgraduate education. We stand by our argument against our response to the earlier consultation document, "Proposals to Introduce Variable Deferred Fees, Access Agreements and a Review of the Student Complaints System" of April 2004, in which we argue against any form of extra tuition fees.
7. On this point, we note the paucity of ideas in (6) of the Explanatory Memorandum and that (6) is not as detailed in its treatment of data collected as it could be. It is striking that the only suggested alternative to top-up fees and graduate contribution was income tax. Certainly, this is an obvious alternative, which would spread the cost among those who on the one hand benefit financially from the increased earning power bestowed (on average) by a degree and those who on the other hand benefit in general terms by having an educated labour force attending their needs (in the fields of education and medicine to name but two). However taxation is not the only alternative source of income that could have been mentioned: industrial sponsorship and alumni are also potential sources of income. The first is already long established and is perhaps already being exploited to near-maximum; the second, while grossly underexploited in the United Kingdom compared with, for example, the United States, it is not in our opinion likely to yield much in the foreseeable future and we do not recommend it as more than a bonus, certainly not as a serious source of core funding. It is therefore not surprising that none of the respondents to the consultation of April 2004 mentioned these sources as serious options.
8. We are curious as to what proportion of respondents suggested which alternative, if any . All that (6) of the Explanatory Memorandum tells us is that "the majority of respondents were in agreement with the need to raise additional funding for higher education" and that "the response was more divided over who should pay". We should like to know in more detail exactly how the response was divided on this point. The wording "Of those not in favour of graduates making an increased contribution towards the cost none suggested an alternative method apart from taxation" implies that increased graduate contribution is to be taken as the preferred method for which no valid alternative was suggested: "apart from taxation" suggests that taxation does not count. While there is insufficient consensus within NPC for us to declare either for or against taxation as a valid alternative to the proposed top-up fees, we would still like to know how many respondents to the April consultation were in favour of raising extra funds for higher education through top-up fees, graduate endowment and general taxation respectively. In the absence of such figures, we cannot rest satisfied that informed opinion, if not the settled will of the people of Northern Ireland and those choosing to study there, is being properly taken into account.
9. We also note that no provision is made to replace the archaic system of Visitor and recommend the Office of the Independent Adjudicator as a model for a suitable replacement.